SEC Comment Letter for ACUITY INC. (DE) (AYI) (CIK 0001144215) (AYI) — Feb 13, 2020
ACUITY INC. (DE) (AYI) (CIK 0001144215)
Date: Feb. 13, 2020 · CIK: 0001144215 · Accession: 0000000000-20-001382
AI Filing Summary & Sentiment
File numbers found in text: 001-16583
Letter
February 13, 2020 Karen J. Holcom Chief Financial Officer ACUITY BRANDS INC 1170 Peachtree Street, N.E., Suite 2300 Atlanta, GA 30309 Re:ACUITY BRANDS INC Form 10-K for the Fiscal Year Ended August 31, 2019 Filed October 29, 2019 File No. 001-16583 Dear Ms. Holcom: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended August 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 23 1.We note that on page 24 and in your earnings releases you present certain non-GAAP measures, such as Adjusted SD&A expenses and Adjusted operating profit, as a percentage of net sales without also presenting the most directly comparable GAAP measures. In addition, you discuss Adjusted operating profit margin in your earnings releases without providing a discussion of GAAP operating profit margin. When presenting or discussing non-GAAP measures in your future filings, please present and discuss the most directly comparable GAAP measures with equal or greater prominence. Refer to Item 10(e)(i)(A) of Regulation S-K and Question 102.10 of the updated Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameKaren J. Holcom Comapany NameACUITY BRANDS INC February 13, 2020 Page 2 FirstName LastName Karen J. Holcom ACUITY BRANDS INC February 13, 2020 Page 2 Notes to Consolidated Financial Statements Note 11 - Commitments and Contingencies, page 70 2.Tell us how your use of the terms "reserve", "reserves" and "reserved" when referring to your accruals for loss contingencies is consistent with the guidance in ASC 450-20-50-1, or revise your disclosures in future filings to comply with the guidance. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact SiSi Cheng at 202-551-5004 or Martin James, Senior Advisor, at 202- 551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
February 13, 2020
Karen J. Holcom
Chief Financial Officer
ACUITY BRANDS INC
1170 Peachtree Street, N.E.,
Suite 2300
Atlanta, GA 30309
Re:ACUITY BRANDS INC
Form 10-K for the Fiscal Year Ended August 31, 2019
Filed October 29, 2019
File No. 001-16583
Dear Ms. Holcom:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended August 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 23
1.We note that on page 24 and in your earnings releases you present certain non-GAAP
measures, such as Adjusted SD&A expenses and Adjusted operating profit, as a
percentage of net sales without also presenting the most directly comparable GAAP
measures. In addition, you discuss Adjusted operating profit margin in your earnings
releases without providing a discussion of GAAP operating profit margin. When
presenting or discussing non-GAAP measures in your future filings, please present and
discuss the most directly comparable GAAP measures with equal or greater prominence.
Refer to Item 10(e)(i)(A) of Regulation S-K and Question 102.10 of the updated
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameKaren J. Holcom
Comapany NameACUITY BRANDS INC
February 13, 2020 Page 2
FirstName LastName
Karen J. Holcom
ACUITY BRANDS INC
February 13, 2020
Page 2
Notes to Consolidated Financial Statements
Note 11 - Commitments and Contingencies, page 70
2.Tell us how your use of the terms "reserve", "reserves" and "reserved" when referring to
your accruals for loss contingencies is consistent with the guidance in ASC 450-20-50-1,
or revise your disclosures in future filings to comply with the guidance.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact SiSi Cheng at 202-551-5004 or Martin James, Senior Advisor, at 202-
551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing